loco parentis doctrine (Pennsylvania) · Go Syfert
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loco parentis doctrine in Pennsylvania

20 Pennsylvania opinions name it 5 courts 1982–2023 2 in the last five years

The cases below were cited by Pennsylvania courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (8)

CaseFollowedCited
Tb v. Lrmgreen
pa · 2001 · cited in 7 Pennsylvania opinions naming this issue, 2007–2016
2 sentences

2016Cognizable rights to custody arise where the legislature specifically authorizes the cause of action, or under the common law doctrine of in loco parentis.5 T.B., supra; J.A.L., supra. In the underlying custody action, the Appellants asserted that they had standing to seek primary physical and shared legal custody pursuant to the following statutory provisions of the Act: § 5324.

2010Pennsylvania recognizes the common law doctrine of in loco parentis. ‘In loco parentis is a legal status and proof of essential facts is required to support a conclusion that such a relationship exists.’ T.B. v. L.R.M., 567 Pa. 222 , 786 A.2d 913, 916 (2001).

57
Stifnell v. Board of Adjustmentgreen
pa · 1968 · cited in 4 Pennsylvania opinions naming this issue, 2001–2001
2 sentences

2001See Commonwealth v. Gerstner, 540 Pa. 116, 124 , 656 A.2d 108, 112 (1995) (“In loco parentis describes a relationship in which one assumes the legal rights and duties of parenthood.” (emphasis in original)); Morgan, 429 Pa. at 565 , 241 A.2d at 533 (in loco parent “puts himself in the situation of a lawful parent by assuming the obligations incident to the parental relationship”); Kransky v. Glen Alden Coal Co., 354 Pa. 425, 428 , 47 A.2d 645, 647 (1946) (in loco parent “assume[s] the rights, duties and responsibilities of a lawful parent to the child”); accord Black’s Law Dictionary 787 (6th

2001See Commonwealth v. Gerstner, 540 Pa. 116, 124 , 656 A.2d 108, 112 (1995) (“In loco parentis describes a relationship in which one assumes the legal rights and duties of parenthood.” (emphasis in original)); Morgan, 429 Pa. at 565 , 241 A.2d at 533 (in loco parent “puts himself in the situation of a lawful parent by assuming the obligations incident to the parental relationship”); Kransky v. Glen Alden Coal Co., 354 Pa. 425, 428 , 47 A.2d 645, 647 (1946) (in loco parent “assume[s] the rights, duties and responsibilities of a lawful parent to the child”); accord Black’s Law Dictionary 787 (6th

44
Commonwealth v. Gerstnergreen
pa · 1995 · cited in 4 Pennsylvania opinions naming this issue, 2001–2001
2 sentences

2001See Commonwealth v. Gerstner, 540 Pa. 116, 124 , 656 A.2d 108, 112 (1995) (“In loco parentis describes a relationship in which one assumes the legal rights and duties of parenthood.” (emphasis in original)); Morgan, 429 Pa. at 565 , 241 A.2d at 533 (in loco parent “puts himself in the situation of a lawful parent by assuming the obligations incident to the parental relationship”); Kransky v. Glen Alden Coal Co., 354 Pa. 425, 428 , 47 A.2d 645, 647 (1946) (in loco parent “assume[s] the rights, duties and responsibilities of a lawful parent to the child”); accord Black’s Law Dictionary 787 (6th

2001See Commonwealth v. Gerstner, 540 Pa. 116, 124 , 656 A.2d 108, 112 (1995) (“In loco parentis describes a relationship in which one assumes the legal rights and duties of parenthood.” (emphasis in original)); Morgan, 429 Pa. at 565 , 241 A.2d at 533 (in loco parent “puts himself in the situation of a lawful parent by assuming the obligations incident to the parental relationship”); Kransky v. Glen Alden Coal Co., 354 Pa. 425, 428 , 47 A.2d 645, 647 (1946) (in loco parent “assume[s] the rights, duties and responsibilities of a lawful parent to the child”); accord Black’s Law Dictionary 787 (6th

44
Kransky v. Glen Alden Coal Co.green
pa · 1946 · cited in 4 Pennsylvania opinions naming this issue, 2001–2001
2 sentences

2001See Commonwealth v. Gerstner, 540 Pa. 116, 124 , 656 A.2d 108, 112 (1995) (“In loco parentis describes a relationship in which one assumes the legal rights and duties of parenthood.” (emphasis in original)); Morgan, 429 Pa. at 565 , 241 A.2d at 533 (in loco parent “puts himself in the situation of a lawful parent by assuming the obligations incident to the parental relationship”); Kransky v. Glen Alden Coal Co., 354 Pa. 425, 428 , 47 A.2d 645, 647 (1946) (in loco parent “assume[s] the rights, duties and responsibilities of a lawful parent to the child”); accord Black’s Law Dictionary 787 (6th

2001See Commonwealth v. Gerstner, 540 Pa. 116, 124 , 656 A.2d 108, 112 (1995) (“In loco parentis describes a relationship in which one assumes the legal rights and duties of parenthood.” (emphasis in original)); Morgan, 429 Pa. at 565 , 241 A.2d at 533 (in loco parent “puts himself in the situation of a lawful parent by assuming the obligations incident to the parental relationship”); Kransky v. Glen Alden Coal Co., 354 Pa. 425, 428 , 47 A.2d 645, 647 (1946) (in loco parent “assume[s] the rights, duties and responsibilities of a lawful parent to the child”); accord Black’s Law Dictionary 787 (6th

44
In Re CBgreen
pasuperct · 2004 · cited in 2 Pennsylvania opinions naming this issue, 2007–2007
2 sentences

2007A recent panel of this Court analyzed this holding, stating that “Davis stands for the sound proposition that the doctrine of in loco parentis should not be employed when determining whether a child has a parent for purposes of determining whether a child is dependent and thus, whether agency involvement should be initiated.” In re C.B., 861 A.2d 287, 297 (Pa.Super.2004).

2007In re Davis, 502 Pa. 110 , 465 A.2d 614 (1983). *274 A recent panel of this Court analyzed this holding, stating that " Davis stands for the sound proposition that the doctrine of in loco parentis should not be employed when determining whether a child has a parent for purposes of determining whether a child is dependent and thus, whether agency involvement should be initiated." In re C.B., 861 A.2d 287, 297 (Pa.Super.2004).

22
Brown v. Commonwealth, Department of Healthgreen
pa · 1981 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023
1 sentence

2023Although Father initially contested Maternal Aunt’s intervention in the custody case, Father then consented to Maternal Aunt sharing custody of the Children with Paternal Grandparents.8 We have long held, “[a] party who has acquiesced in an order or judgment will not later be heard to challenge it." Karkaria v. Karkaria, 592 A.2d 64, 71 (Pa. Super. 1991) (citing Brown v. Commonwealth, Department of Health, 434 A.2d 1179 (Pa. 1981) (“Ordinarily, a party who consents to, or acquiesces in, a judgment or order cannot appeal therefrom.”)).

11
Karkaria v. Karkariagreen
pasuperct · 1991 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023
1 sentence

2023Although Father initially contested Maternal Aunt’s intervention in the custody case, Father then consented to Maternal Aunt sharing custody of the Children with Paternal Grandparents.8 We have long held, “[a] party who has acquiesced in an order or judgment will not later be heard to challenge it." Karkaria v. Karkaria, 592 A.2d 64, 71 (Pa. Super. 1991) (citing Brown v. Commonwealth, Department of Health, 434 A.2d 1179 (Pa. 1981) (“Ordinarily, a party who consents to, or acquiesces in, a judgment or order cannot appeal therefrom.”)).

11
K.W. v. S.L.green
pasuperct · 2017 · cited in 1 Pennsylvania opinions naming this issue, 2018–2018
1 sentence

2018Beltran v. Piersody, 748 A.2d 715 (Pa. Super. 2000); see also K.W. v. S.L., 157 A.3d 498, 502 (Pa. Super. 2017) (“Father concedes that the [order granting (Footnote Continued Next Page) J-S75015-17 Mother and D.W. (“Father”), are the natural parents of Child, born in October of 2006.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Pennsylvania. Read the followed side critically anyway.

Also cited on this issue (11)

CaseCitedYears
Jal v. Eph green
pasuperct · 1996
2 sentences

2016Cognizable rights to custody arise where the legislature specifically authorizes the cause of action, or under the common law doctrine of in loco parentis.5 T.B., supra; J.A.L., supra. In the underlying custody action, the Appellants asserted that they had standing to seek primary physical and shared legal custody pursuant to the following statutory provisions of the Act: § 5324.

2001On March 17, 1997, a hearing officer held a hearing on both standing and custody/visitation. 3 Relying on J.A.L. v. E.P.H., 453 Pa.Super. 78 , 682 A.2d 1314 (1996), the hearing officer concluded that Appellee had standing to seek custody/visitation pursuant to the doctrine of in loco parentis.

52001–2016
T.B. v. L.R.M. green
pa · 2001
2 sentences

2010Pennsylvania recognizes the common law doctrine of in loco parentis. ‘In loco parentis is a legal status and proof of essential facts is required to support a conclusion that such a relationship exists.’ T.B. v. L.R.M., 567 Pa. 222 , 786 A.2d 913, 916 (2001).

2010Pennsylvania recognizes the common law doctrine of in loco parentis. `In loco parentis is a legal status and proof of essential facts is required to support a conclusion that such a relationship exists.' T.B. v. L.R.M., 567 Pa. 222 , 786 A.2d 913, 916 (2001).

52007–2013
Commonwealth ex rel. Morgan v. Smith green
pa · 1968
2 sentences

2001See Commonwealth v. Gerstner, 540 Pa. 116, 124 , 656 A.2d 108, 112 (1995) (“In loco parentis describes a relationship in which one assumes the legal rights and duties of parenthood.” (emphasis in original)); Morgan, 429 Pa. at 565 , 241 A.2d at 533 (in loco parent “puts himself in the situation of a lawful parent by assuming the obligations incident to the parental relationship”); Kransky v. Glen Alden Coal Co., 354 Pa. 425, 428 , 47 A.2d 645, 647 (1946) (in loco parent “assume[s] the rights, duties and responsibilities of a lawful parent to the child”); accord Black’s Law Dictionary 787 (6th

2001See Commonwealth v. Gerstner, 540 Pa. 116, 124 , 656 A.2d 108, 112 (1995) (“In loco parentis describes a relationship in which one assumes the legal rights and duties of parenthood.” (emphasis in original)); Morgan, 429 Pa. at 565 , 241 A.2d at 533 (in loco parent “puts himself in the situation of a lawful parent by assuming the obligations incident to the parental relationship”); Kransky v. Glen Alden Coal Co., 354 Pa. 425, 428 , 47 A.2d 645, 647 (1946) (in loco parent “assume[s] the rights, duties and responsibilities of a lawful parent to the child”); accord Black’s Law Dictionary 787 (6th

42001–2001
In Re Davis green
pasuperct · 1981
2 sentences

2007In re Davis, 288 Pa.Super. 453 , 432 A.2d 600 (1981); see also 42 Pa.C.S.A. § 6302, Dependent child, (4) (stating that a child without a parent, guardian, or legal custodian is a dependent child).

2007In re Davis, 288 Pa.Super. 453 , 432 A.2d 600 (1981); see also 42 Pa.C.S.A. § 6302, Dependent child, (4) (stating that a child without a parent, guardian, or legal custodian is a dependent child).

22007–2007
E.A., III v. E.C. green
pasuperct · 2021
1 sentence

2022Grandparents present the following issues for our review: (1) Did the trial court err as a matter of law in conflating standing for grandparents pursuant to the in loco parentis doctrine and standing pursuant to 23 Pa.C.S. § 5325? (2) Did the trial court err as a matter of law in dismissing grandparents’ petition for partial custody based on a lack of standing? (3) Did the trial court err as a matter of law in denying grandparents’ standing pursuant to the recently decided case of E.A., III v. E.C., [ 259 A.3d 497 (Pa. Super. 2021)]? (4) Did the trial court err as a matter of law in denying gr

12022–2022
Beltran v. Piersody green
pasuperct · 2000
1 sentence

2018Beltran v. Piersody, 748 A.2d 715 (Pa. Super. 2000); see also K.W. v. S.L., 157 A.3d 498, 502 (Pa. Super. 2017) (“Father concedes that the [order granting (Footnote Continued Next Page) J-S75015-17 Mother and D.W. (“Father”), are the natural parents of Child, born in October of 2006.

12018–2018
D.G. v. D.B. green
pasuperct · 2014
1 sentence

2018Likewise, in D.G. v. D.B. and G.V., 91 A.3d 706 (Pa. Super. 2014), grandmother's role was held to be that of caretaker and therefore lacked standing to seek primary physical custody under the in loco parentis doctrine.

12018–2018
In Re Davis green
pa · 1983
2 sentences

2007In re Davis, 502 Pa. 110 , 465 A.2d 614 (1983). *274 A recent panel of this Court analyzed this holding, stating that " Davis stands for the sound proposition that the doctrine of in loco parentis should not be employed when determining whether a child has a parent for purposes of determining whether a child is dependent and thus, whether agency involvement should be initiated." In re C.B., 861 A.2d 287, 297 (Pa.Super.2004).

2007In re Davis, 502 Pa. 110 , 465 A.2d 614 (1983). *274 A recent panel of this Court analyzed this holding, stating that " Davis stands for the sound proposition that the doctrine of in loco parentis should not be employed when determining whether a child has a parent for purposes of determining whether a child is dependent and thus, whether agency involvement should be initiated." In re C.B., 861 A.2d 287, 297 (Pa.Super.2004).

12007–2007
Peters v. Costello green
pa · 2005
1 sentence

2007We acknowledge that the Peters court expressly noted that the in loco parentis doctrine has been invoked “almost exclusively in matters of child custody.” Peters at 111 n.1, 891 A.2d at 710 n.1.

12007–2007
Commonwealth Ex Rel. Bulson v. Bulson green
pasuperct · 1980
2 sentences

1984We affirmed, discussing the doctrine of in loco parentis, and stating that the lower court had, “ample evidence from which to infer that appellant had assumed the obligation himself when he married appellant, knowing that she had a child in need of support.” Bulson v. Bulson, supra 278 Pa.Super. at 10 , 419 A.2d at 1329 .

1984We affirmed, discussing the doctrine of in loco parentis, and stating that the lower court had, “ample evidence from which to infer that appellant had assumed the obligation himself when he married appellant, knowing that she had a child in need of support.” Bulson v. Bulson, supra 278 Pa.Super. at 10 , 419 A.2d at 1329 .

11984–1984
Rutkowski v. Wasko green
nyappdiv · 1955
1 sentence

1982In a New York case, Rutkowski v. Wasko, 143 N.Y.S. 2d 1 , (1955), where it was to the child’s best interest that a stepfather be found not to be in loco parentis (because it would deny the child a tort recovery), we find an excellent exposition of the doctrine of in loco parentis.

11982–1982

Statutes the citing opinions construe

PA § 23 Pa. Cons. Stat. § 1704 (4)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

MS 22 (2002–2025) PA 20 (1982–2023) NY 10 (1971–2026) WA 8 (1995–2020) TX 8 (1949–2009) NE 7 (1992–2025) OH 7 (2002–2024) FL 7 (1975–2015) AR 6 (1997–2016) KS 6 (1993–2024) NJ 6 (2002–2007) CA 5 (1984–2015) WV 5 (1982–2024) UT 5 (2001–2018) IN 4 (2011–2013) IL 4 (1987–2012) MI 4 (2010–2024) IA 4 (2015–2025) NH 2 (1999–2021) GA 2 (1980–1989) WI 2 (1994–2002) OK 2 (2019–2019) MO 2 (1981–2015) LA 2 (2015–2016) DE 2 (2010–2022) MD 2 (2015–2016) MA 2 (1990–2015)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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